What is Vodafone International Holdings BV v. Union of India authority for?

Ambiguity in tax statutes and explanations must be resolved in favor of the assessee. Tax Residency Certificates (TRCs) are conclusive proof of residency for treaty benefits unless fraud or treaty shopping is established, validating legitimate holding structures and Special Purpose Vehicles (SPVs).

Which sections of the Income Tax Act does Vodafone International Holdings BV v. Union of India come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 263, Section 147, Section 148, Section 131(1A).

Vodafone International Holdings BV v. Union of India (6 SCC 613)

Q: How many judgments cite Vodafone International Holdings BV v. Union of India?

216 judgments on BharatTax cite Vodafone International Holdings BV v. Union of India (6 SCC 613), spanning 2012 to 2026.

THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) vs. TIGER GLOBAL INTERNATIONAL II HOLDINGS

C.A. No.-000262-000262 - 2026Supreme Court15 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

…Holdings BV v. Union of India12 that the DTAA and Circular No.789 dated 13.04.2000 would not preclude the Income Tax Department from denying treaty benefits in suitable cases. It was further held that the Department is entitled to examine the 12 (2012) 6 SCC 613 (3 Judge Bench) 18 entire transaction as a whole, and if it is established that the Mauritian company was interposed as a device, it would be open to the Department to discard the device and subject the real transaction to tax. 6.8. The AAR further found that though tax residency was claimed to have been established to take advantage of…

ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed

ITA 5350/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16

Section 115JSection 143(3)Section 14ASection 250

…uity in the language of Explanation 3C shall be resolved in\nfavour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner\n(supra) as followed by judgments of this Court - See Vodafone International Holdings BV\nv. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C. J. and para 333,\n334 per Radhakrishnan, J.\"\n47.\nAccording to Ld. AR, therefore the amendment brought in by Finance Act, 2022\ncannot be said to be retrospective and for that proposition he cited the Constitution\nBench decision of the Hon'ble Supreme Court in the case of CIT vs. Vatika Township Pvt.\nLtd. (supr…

ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed

ITA 5349/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Hemanshu Joshi, SR DR

Section 115JSection 143(2)Section 143(3)Section 14ASection 250

…biguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C. J. and para 333, 334 per Radhakrishnan, J." 47. According to Ld. AR, therefore the amendment brought in by Finance Act, 2022 cannot be said to be retrospective and for that proposition he cited the Constitution Bench decision of the Hon'ble Supreme Court in the case of CIT vs. Vatika Township Pvt. Ltd. (supra) wher…

CPI INDIA I LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE INT TAX 1(2)(1), DELHI, DELHI

In the result, appeal of the assessee is partly allowed

ITA 1826/DEL/2025[2018-2019]Status: DisposedITAT Delhi31 Oct 2025AY 2018-2019

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.1826/िद"ी/2025(िन.व. 2018-19) Cpi India I Ltd. C/O Vasa Chauhan & Associates, Off. No. 41, 3Rd Floor, Hi Life Premises, P M Road, Santacruz West, Mumbai, Maharashtra 400054 ...... अपीलाथ"/Appellant Pan: Aadcc-1505-G बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri Dhanesh Bafna, (Through Vc) & Ms. Kashish Gupta, Chartered Accountants "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 05/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 31.01.2025 Passed U/S. 147 R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2018-19. 2. Shri Dhanesh Bafna, Appearing On Behalf Of The Assessee Submits That The Assessee Is A Tax Resident Of Mauritius. The Assesee Is An Investment Holding Company. The Assessee Has Obtained Global Business License From The Financial

For Appellant: Shri Dhanesh Bafna, (Through VC) &For Respondent: Shri M.S Nethrapal, CIT-DR

Section 112(1)(c)Section 147Section 48

…आयकर अपीलीय अिधकरण िद"ी पीठ “डी”, िद"ी "ी िवकास अव"थी, "ाियक सद" एवं "ी "जेश कुमार िसंह, लेखाकार सद" के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER आअसं.1826/िद"ी/2025(िन.व. 2018-19) CPI India I Ltd. C/o Vasa Chauhan and Associates, Off. No. 41, 3rd Floor, Hi Life Premises, P M Road, Santacruz West, Mumbai, Maharashtra 400054 ...... अपीलाथ"/Appellant PAN: AADCC-1505-G बनाम Vs. Assistant Commissioner of Income-Tax, International Taxation 1(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi…

ROHIT PRAKASHCHANDRA SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(2)(3),, AHMEDABAD

In the result, appeal preferred by the assessee is dismissed

ITA 128/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 147Section 148

…THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH, AHMEDABAD BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER Assessment Year: 2014-15 Rohit Prakashchandra Shah, Income Tax Officer, B-339, Advance Business Ward – 1(2)(3), Park, Aaykar Bhavan (Vejalpur), Opp. Swaminarayan Temple, Nr. Sachin Tower, Shahibaug, 100 Foot Road, Vs. Ahmedabad – 380 004 Anandnagar-Prahladnagar (Gujarat) Road, [PAN – AXRPS 8716 R] Ahmedabad – 380 015. (Gujarat) (Appellant) (Respondent) Assessee by Shri K. C. Thaker, AR Revenue by Shri Abhijit, Sr. DR Date of Hearing 23.09.2025 Date of Pron…

SKY HIGH II LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1550/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…eld that –  The assessee had a valid Tax Residency Certificate (TRC) issued by Irish authorities. The Hon'ble Supreme Court rulings in Union of India v. Azadi Bachao Andolan&Anr. (2004) 10 SCC 1 and Vodafone International Holdings BV v. Union of India (2012) 6 SCC 613 has held that such certificates were conclusive of residency unless fraud or treaty shopping was proved.  It could not be presumed that Irish authorities issued TRCs without proper application of mind, particularly when the PPT was a globally recognized standard.  The assessee operated through a legitimate corporate structure in Ireland and its d…

SKY HIGH LXXX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1549/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…eld that –  The assessee had a valid Tax Residency Certificate (TRC) issued by Irish authorities. The Hon'ble Supreme Court rulings in Union of India v. Azadi Bachao Andolan&Anr. (2004) 10 SCC 1 and Vodafone International Holdings BV v. Union of India (2012) 6 SCC 613 has held that such certificates were conclusive of residency unless fraud or treaty shopping was proved.  It could not be presumed that Irish authorities issued TRCs without proper application of mind, particularly when the PPT was a globally recognized standard.  The assessee operated through a legitimate corporate structure in Ireland and its d…

SKY HIGH LXXVIII LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1548/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…eld that –  The assessee had a valid Tax Residency Certificate (TRC) issued by Irish authorities. The Hon'ble Supreme Court rulings in Union of India v. Azadi Bachao Andolan&Anr. (2004) 10 SCC 1 and Vodafone International Holdings BV v. Union of India (2012) 6 SCC 613 has held that such certificates were conclusive of residency unless fraud or treaty shopping was proved.  It could not be presumed that Irish authorities issued TRCs without proper application of mind, particularly when the PPT was a globally recognized standard.  The assessee operated through a legitimate corporate structure in Ireland and its d…

SKY HIGH XC LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1547/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Section 143(3)Section 234B

…eld that\nThe assessee had a valid Tax Residency Certificate (TRC) issued by Irish\nauthorities. The Hon'ble Supreme Court rulings in Union of India v. Azadi Bachao\nAndolan&Anr. (2004) 10 SCC 1 and Vodafone International Holdings BV v.\nUnion of India (2012) 6 SCC 613 has held that such certificates were conclusive\nof residency unless fraud or treaty shopping was proved.\nIt could not be presumed that Irish authorities issued TRCs without proper\napplication of mind, particularly when the PPT was a globally recognized\nstandard.\nThe assessee operated through a legitimate corporate structure in Ireland and its\…

SKY HIGH LXXIX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1546/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…eld that –  The assessee had a valid Tax Residency Certificate (TRC) issued by Irish authorities. The Hon'ble Supreme Court rulings in Union of India v. Azadi Bachao Andolan&Anr. (2004) 10 SCC 1 and Vodafone International Holdings BV v. Union of India (2012) 6 SCC 613 has held that such certificates were conclusive of residency unless fraud or treaty shopping was proved.  It could not be presumed that Irish authorities issued TRCs without proper application of mind, particularly when the PPT was a globally recognized standard.  The assessee operated through a legitimate corporate structure in Ireland and its d…

INCOME TAX OFFICER WARD-1 JHUNJHUNU, JHUNJHUNU vs. BAGARIA TRADE IMPEX, CHURU

In the result, appeal of the Revenue is allowed and order of the AO is\nconfirmed

ITA 705/JPR/2025[2013-14]Status: DisposedITAT Jaipur29 Sept 2025AY 2013-14

Section 143(2)Section 143(3)Section 147Section 250Section 68

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nJAIPUR BENCH “A”, JAIPUR\nBEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND\nSHRI GAGAN GOYAL, ACCOUNTANT MEMBER\nITA Nos.696, 697 & 705/JPR/2025 (A. Y. 2013-14 & 2014-15)\nIncome Tax Officer,\nWard-01,\nJhunjhunu\nVs.\nAppellant\nBagaria Trade Impex,\nNear, State Bank of India,\nChuru 331 001\nRespondent\nPAN No.: AALFB 6581E\nAppellant by\n: Mr. Sandeep Goel, Adv., Ld. AR\nRespondent by\n: Mrs. Anita Rinesh, JCIT-DR\nDate of hearing\n: 11/09/2025\nDate of pronouncement : 29/09/2025\nORDER\nPER GAGAN GOYAL, A.M:\nThese three appeals by revenue are directed…

INCOME TAX OFFICER WARD 1 JHUNJHUNU, JHUNJHUNU vs. BAGARIA TRADE IMPEX, CHURU

In the result, appeal of the Revenue is allowed and order of the AO is\nconfirmed

ITA 697/JPR/2025[2014-15]Status: DisposedITAT Jaipur29 Sept 2025AY 2014-15

For Appellant: \nMr. Sandeep Goel, Adv., Ld. ARFor Respondent: \nMrs. Anita Rinesh, JCIT-DR

Section 143(2)Section 143(3)Section 147Section 250Section 68

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nJAIPUR BENCH “A”, JAIPUR\nBEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND\nSHRI GAGAN GOYAL, ACCOUNTANT MEMBER\nITA Nos.696, 697 & 705/JPR/2025 (A. Y. 2013-14 & 2014-15)\nIncome Tax Officer,\nWard-01,\nJhunjhunu Appellant\nVs.\nBagaria Trade Impex,\nNear, State Bank of India,\nChuru 331 001\nPAN No.: AALFB 6581E Respondent\nAppellant by :\nMr. Sandeep Goel, Adv., Ld. AR\nRespondent by :\nMrs. Anita Rinesh, JCIT-DR\nDate of hearing : 11/09/2025\nDate of pronouncement : 29/09/2025\nORDER\nPER GAGAN GOYAL, A.M:\nThese three appeals by revenue are directed aga…

INCOME TAX OFFICER WARD 1 JHUNJHUNU, JHUNJHUNU vs. BAGARIA TRADE IMPEX, CHURU

In the result, appeal of the Revenue is allowed and order of the AO is\nconfirmed

ITA 696/JPR/2025[2013-14]Status: DisposedITAT Jaipur29 Sept 2025AY 2013-14

Section 143(2)Section 143(3)Section 147Section 250Section 68

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nJAIPUR BENCH “A”, JAIPUR\nBEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND\nSHRI GAGAN GOYAL, ACCOUNTANT MEMBER\nITA Nos.696, 697 & 705/JPR/2025 (A. Y. 2013-14 & 2014-15)\n\nIncome Tax Officer,\nWard-01,\nJhunjhunu\n\nBagaria Trade Impex,\nNear, State Bank of India,\nChuru 331 001\nPAN No.: AALFB 6581E\n\nAppellant\n\nVs.\n\nRespondent\n\nAppellant by\n: Mr. Sandeep Goel, Adv., Ld. AR\nRespondent by\n: Mrs. Anita Rinesh, JCIT-DR\nDate of hearing\n: 11/09/2025\nDate of pronouncement : 29/09/2025\n\nORDER\nPER GAGAN GOYAL, A.M:\n\nThese three appeals by reven…